Certificate of Conformance vs. 8130? 1

[KirbyWan]

Howdy all,

I have a question about when an 8130 is required compared with when a certificate of conformance (CofC) would be acceptable when an outside vendor performs a process or inspection. Here are some example situations:
[ol 1]
[li]Company A, an FAA repair station wants a flame spray process performed on a component that they are overhauling, but do not have the capability. They send it to an outside vendor, Company B, who has the capability and can perform the process per the specification in the manual. Will a CofC from the outside vendor be enough or is an 8130 required?[/li]
[li]Company A, an FAA repair station, does not have NDT capabilities, so they send their FPI work it to Company B, also an FAA repair station with FPI capability to perform the inspections required per the manual. ?[/li]
[li]Company A, an FAA repair station, has NDT on their capabilities list but only FPI and MFPI, not X-ray that is required for an inspection so they send it to company B. Would a CofC be enough or is an 8130 required?[/li]
[/ol]
The assumption in each case is that Company A is going to provide an 8130 to certify the overhauled component is airworthy.

I'm just looking for guidance, as people have differing opinions on what is required. If you could provide a document that could substantiate your understanding that would be even better.

Thanks,

-Kirby

Kirby Wilkerson

Remember, first define the problem, then solve it.

 

[debodine]

As you noted, you may get a range of opinions about the FAA Form 8130-3 usage. I will take my shot at answering your question.

The document to refer to for using the FAA Form 8130-3 is FAA Order 8130.21E, and paragraph 101 describes appropriate situations for use of the form. Paragraph 101.b. "Approval for return to service of products and parts" covers your situation, I believe.

In all three of your cases, Company A is going to establish FAA approval of the part with an 8130-3, and paragraph 301.a. and 301.b. govern who is authorized to release the 8130-3 for the part. In all three of your cases, Company B is not establishing FAA approval of the part.

As long as the P.O. from Company A specifies exactly what must occur and to what standard, and the quality system of Company A has the ability to incoming inspect the part against the P.O. requirements and archive the Company B CofC that accompanied the part showing that the P.O. requirements were met, that should establish the paper trail from the FAA approval provided by Company A to the work done by Company B.

 

[debodine]

I was unforgivably slack in my research. The correct, current revision level is FAA Order 8130.21H, not E.

Paragraph reference 101 should be 1-1 and 101.b. should be 1-1.b.

Paragraph reference 301.a. should be 3-1.a. and 301.b. should be 3-1.b.

I apologize for such sloppiness. I will do better in the future.

 

[KirbyWan]

Thank you for your response debodine. The 8130-21H has a specific mention that one of the options for box 11 is inspected, but I read that as being used when that is all that is needed and if it passes inspection it is acceptable to return to service. In cases 2 and 3 above I think of it as a check and an indication might lead to rework before return to service. I agree with your assessment, now if I can convince our quality team and customers of that. No worries about the revision change.

-Kirby

Kirby Wilkerson

Remember, first define the problem, then solve it.

 

[debodine]

You are welcome. I hope that you have success discussing the FAA Order with your quality team and customers.

 

[cjohnso0]

Kirby,

Not sure if you've solved your certification issues yet, but I've got a few comments from my 13 years in FAA repair stations.

Your QC team should discuss this with your PMI. Every repair station and PMI is a bit different in how they handle this, as the Regulations are vague.

Here's what we do:
Any sub-contractor work on a FAA repair part needs to be performed by an FAA Repair Station*, they are required to send us an 8130-3 for all work performed, which typically mimics our PO verbiage. These are normally "Repaired" certs.

* Non-FAA repair stations are not permitted to work on our parts. We do have a process in which we cover one or two people in their shops under our Drug and Alcohol Program, and our RS Certificate so they can perform work for us, discuss with PMI.

My interpretation of the various Block 11 wordings is:

Overhauled: Cleaned, Inspected, Repaired per approved tech data, ready for return to service

Inspected: Inspected per approved tech data, may be ready for return to service, or may need additional 8130's.

Repaired: Repaired per approved tech data, still requires inspection for return to service.

We issue either of these, depending on our customer's purchase order, the rest is up to them.

Chris

 

[KirbyWan]

Thanks for your response Chris,

I'm not in the Quality department and I'm not the one talking to the PMI. Mostly the reason I'm asking the question here is that I'm getting the sense of confusion from everyone who are not really sure what is required or acceptable because of that vagueness. I think part of the problem stems from different PMIs interpret things differently and if you've ended up dealing with more then on you've faced contradictory requirements. I was just looking for a perspective of what other people are used to as a guide to what's normal.

-Kirby

Kirby Wilkerson

Remember, first define the problem, then solve it.